- agrees with this proposed Regulation and its aim to boost investment across the EU but is unclear as to whether the investment arising from this initiative will remain within the EU and also to the impact on labour mobility across the EU arising from the provision of PEPPs;
- acknowledges that PEPPs are most likely to appeal to a limited number of groups, particularly, mobile professionals who work in a number of different Member States over their working life, and the self-employed;
- however points out that this initiative should not in any way be construed as lessening the relevance of either state or work-based pensions
- considers that Member States should provide fair taxation on this type of product;
- emphasises the need for consumer protection and risk mitigation for savers during the course of their working lives and on retirement. Greater clarity as to what is being guaranteed around the default option is also strongly recommended. It is of crucial importance that savers are fully aware of the risks that they bear and the conditions attached to their PEPP;
- emphasises the role of EIOPA in monitoring the market and national supervisory regimes with a view to achieving convergence and consistency across the EU especially regarding the governance structure for PEPPs within any provider;
- seeks clarity on the fee for changing PEPP providers, and proposes examining to waive that fee following a defined period of time.
Personal pension products: The Commission is exploring ways to increase choices for retirement saving and build an EU market for personal pensions - Commission website dedicated to the PEPP.